Privacy Policy

Last updated: July 2, 2020

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

INTERPRETATION AND DEFINITIONS

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.  Under GDPR, if applicable, You can be referred to as the Data Subject (as defined in the GDPR) or as the User as you are the individual using the Service.  Under CCPA, if applicable, You may be referred to as a Consumer.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Sirius Technology Advanced Research, LLC and its affiliates and subsidiaries.  For the purpose of the GDPR, the Company is the Data Controller.  For the purpose of the CCPA, the Company is the legal entity that collects Consumers’ Personal Data and determines the purposes and means of the processing of Consumers’ Personal Data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information.
• Application means the software program provided by the Company downloaded by You on any electronic device, named CE5 Contact.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Account means a unique account created for You to access our Service or parts of our Service.
• Service refers to use of the Application or when You visit the website https://siriusdisclosure.com/ or any other website owned or operated by Us.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.  For the purpose of the GDPR, Service Providers are considered Data Processors.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Facebook Fan Page is a public profile named Dr. Steven Greer specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/doctorstevengreer/
• Personal Data is any information that relates to an identified or identifiable individual.  For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.  For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with You or your household except (i) publicly available information from government records, (ii) deidentified or aggregated Consumer information, and (iii) information specifically excluded by the CCPA.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in California who is outside California for a temporary or transitory purpose.
• Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Data to another business or a third party for monetary or other valuable consideration.
• GDPR means, as may be amended from time to time, Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).  Any Services and terms of this Privacy Policy subject to the GDPR only apply to Data Subjects
• CCPA means, as may be amended from time to time, the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 to 1798.199) and any related regulations or guidance provided by the California Attorney General.  Any Services and terms of this Privacy Policy subject to the CCPA only apply to Consumers.

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a User of the Service. The Personal Data that You provide can give You access to different functionalities of the Service that are available to You as a registered User.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For any other purpose for which you provide it, that you consent to, or that we describe at the time it is collected.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. Your information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.  Any transmission of Personal Data is at your own risk.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

ANALYTICS

We may use third-party Service Providers to monitor certain Personal Data and analyze the use of our Service.

• Google Analytics: a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

EMAIL MARKETING

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

• Constant Contact: an email marketing sending service provided by Constant Contact, Inc.
• For more information on the privacy practices of Constant Contact, please visit their Privacy policy: https://www.constantcontact.com/forward/privacy-center

GDPR PRIVACY (FOR EUROPEAN UNION RESIDENTS ONLY)

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

FACEBOOK FAN PAGE

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page (https://www.facebook.com/doctorstevengreer/), the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our Users.

For this purpose, Facebook places a Cookie on the device of the User visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the User visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

CCPA PRIVACY (FOR CALIFORNIA CONSUMERS ONLY)

Your Rights under the CCPA

If You are a California Consumer, under this Privacy Policy and by law, You have the following rights:

• The right to notice. You must be properly notified which categories of Personal Data are being collected, the categories of third parties to whom Personal Data is disclosed for a business purpose, the categories of Personal Data disclosed to third parties for a business purpose, and the purposes for which the Personal Data is being used.  The categories of such third parties are: service providers, subsidiaries and affiliates, and all other third parties identified in this Privacy Policy.  The categories of Personal Data collected by Us include:
  • Identifiers
  • Personal information categories listed in the California Customer Records statute (Cal.  Civ.  Code § 1798.80(e))
  • Protected classification characteristics under California or federal law (i.e., age)
  • Commercial information (i.e., purchase history)
  • Internet or other similar network activity
  • Geolocation data depending on your settings and the Device You use

Those categories of collected Personal Data have also been disclosed (but not sold) to third parties for a business purpose.

• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding Personal Data that has been collected and disclosed in the past 12 months by the Company to a third party for a business purpose.
• The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months subject to certain exceptions.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California Consumer, You can submit a verifiable consumer request via the methods listed at the bottom of this Privacy Policy.  Only You, or someone legally authorized to act on Your behalf, may make a verifiable consumer request related to Your Personal Data.  You may also make a verifiable consumer request on behalf of Your minor child as discussed below.  The verifiable consumer request must (a) provide sufficient information that allows Us to reasonably verify You are the person about whom we collected Personal Data or an authorized representative and (b) describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.  You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable consumer request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

DO NOT SELL MY PERSONAL INFORMATION

We do not sell Personal Data. However, Service Providers we may choose to partner with (for example, advertising partners) may use technology on the Service that “sells” Personal Data as defined by the CCPA law.

If You wish to opt out of the use of Your Personal Data for interest-based advertising purposes and these potential Sales as defined under CCPA law, You may contact Us using the methods listed at the bottom of this Privacy Policy.

Please note that any opt out is specific to the browser or device You use. You may need to opt out on every browser or device that you use.

WEBSITE

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• From Our “Cookie Consent” notice banner
• Or from Our “CCPA Opt-out” notice banner
• Or from Our “Do Not Sell My Personal Information” notice banner
• Or from Our “Do Not Sell My Personal Information” link

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.

MOBILE DEVICES

Your mobile device may give you the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to your interests

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

“DO NOT TRACK” POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA)

Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

CHILDREN’S PRIVACY

The Service may contain content appropriate for children under the age of 13. As a parent, you should know that through the Service children under the age of 13 may participate in activities that involve the collection or use of Personal Data. We use reasonable efforts to ensure that before we collect any Personal Data from a child, the child’s parent receives notice of and consents to our Personal Data collection practices.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these Users. If We need to rely on consent as a legal basis for processing Your information and Your jurisdiction requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

We may ask a User to verify its date of birth before collecting any Personal Data from them. If the User is under the age of 13, the Service will be either blocked or redirected to a parental consent process.  We currently do not sell Personal Data of anyone but, for clarity with respect to the CCPA, we will not sell the Personal Data of anyone under the age of 13 without the consent of the child’s parent or legal guardian or of the Consumer if between the ages of 13 and 16.

Information Collected from Children Under the Age of 13

The Company may collect and store persistent identifiers such as cookies or IP addresses from children without parental consent for the purpose of supporting the internal operation of the Service.

We may collect and store other Personal Data about children if this information is submitted by a child with prior parent consent or by the parent or guardian of the child.

The Company may collect and store the following types of Personal Data about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:

• First and/or last name
• Date of birth
• Gender
• Grade level
• Email address
• Telephone number
• Parent’s or guardian’s name
• Parent’s or guardian’s email address

For further details on the information We might collect, You can refer to the “Types of Data Collected” section of this Privacy Policy. We follow our standard Privacy Policy for the disclosure of Personal Data collected from and about children.

PARENTAL ACCESS

A parent who has already given the Company permission to collect and use a child’s Personal Data can, at any time:

• Review, correct or delete the child’s Personal Data
• Discontinue further collection or use of the child’s Personal Data

To make such a request, You can write to Us using the contact information provided in this Privacy Policy.

YOUR CALIFORNIA PRIVACY RIGHTS (CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered Users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If You have any questions about this Privacy Policy, You can contact us:

• By email: info@siriusdisclosure.com